Pharmaceutical Network Tax Optimization

A major pharmacy chain operating across CIS markets and the UAE was carrying a fragmented contractual setup between its entities in two regions. The group needed a coherent structure that would align intercompany flows, supply chain arrangements, and tax exposure across very different regulatory environments. Without a unified framework, the chain faced overlapping tax burdens, inefficient cross-border supply terms, and rising friction between its CIS operations and its UAE presence. The client needed a single legal architecture that could hold the network together — before continued growth locked in further structural costs.

We designed a multi-jurisdictional contractual framework that aligned the group's CIS and UAE operations end to end:

1. Structural review — mapped the existing entity setup, intercompany flows, and supply chain across both regions to surface the points of tax leakage.
2. Contractual framework — built a multi-jurisdictional set of intercompany agreements that allocated functions, risks, and margins consistently between CIS and UAE entities.
3. Supply chain optimization — restructured the flow of goods and services within the network so that operational logistics matched the new contractual model.
4. Tax alignment — calibrated the framework to minimize tax exposure across both regions while keeping the structure defensible and operationally workable.